Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...
Income Tax : Understand USA corporate tax in 2024, including tax rates, filing deadlines, estimated payments, EINs, and penalties. Stay complia...
Income Tax : CIT International Tax- 1 Vs Expeditors International of Washington INC (Delhi High Court); ITA 202/2022; Dated: 13/02/2025 In a si...
Income Tax : Stay updated with 2024 US individual tax filing details, including deadlines, tax rates, forms, and standard deductions. Learn abo...
Income Tax : Learn about income tax filing requirements for proprietors in the USA, including forms, schedules, deductions, deadlines, and pena...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement ...
Income Tax : Forms 1042, 1042-S, and 1042-T are U.S I.R.S taxation forms dealing with dealings with foreign persons, including non-resident ali...
Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...
Income Tax : CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of In...
Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...
Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...
Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
Interworld Shipping Agency LLC Vs DCIT (ITAT Mumbai) The short issue that we are actually required to adjudicate, in this appeal, is whether or not the authorities below were justified in declining the benefits of India UAE Double Taxation Avoidance Agreement [(1995) 205 ITR Stat 49; Indo-UAE tax treaty, in short] to the assessee appellant. […]
Withholding tax rate of 5% is to be applied while making payment of dividend by Indian entity to its shareholder in Netherlands after applying the Most Favoured Nation (MFN) clause in the Tax Treaty between India and Netherlands.
As per the tax plan, following are the flaws in the current tax system: (i) Evidence following the 2017 corporate rate cut from 35 percent to 21 percent, however, did not show an increase in investment or economic growth from trend levels. (ii) The share of federal revenue raised by the corporate tax has fallen […]
Vide Notification No. 31/2021-Income-tax Dated 5th April, 2021 CBDT notifies amendment in Rule 10DA which deals with Maintenance and furnishing of information and document by certain person under section 92D, Rule 10DB which deals with Furnishing of Report in respect of an International Group & Form No. 3CEAB which is Intimation by a designated constituent […]
CBDT notifies Agreement Between The Government Of The Republic Of India And The Government Of The Islamic Republic Of Iran For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income. Notification No. 29/2021-Income-tax Dated 1st April, 2021. MINISTRY OF FINANCE (Department of Revenue) New Delhi Notification No. […]
Nowadays on account of the globalized environment and expansion of business outside India, a person may earn income from more than one country and sometimes the same income may be taxed twice, once in the source country and other in the resident country as well. Let us know these two methods for taxing income earned by a person in more detail.
1. The option to accelerate the write-off of the cost of acquiring qualifying plant and machinery will be extended to qualifying capital expenditure incurred on the acquisition of plant and machinery in the basis period for YA 2022 i.e. financial year (FY) 2021. 2. Providing an option to accelerate the deduction of qualifying expenditure incurred […]
ABSA Bank Limited Vs Commissioner, South African Revenue Service (High Court of South Africa) FULL TEXT OF THE JUDGMENT/ORDER of SOUTH AFRICA HIGH COURT Introduction [1] The applicants, Absa Bank Ltd and its wholly owned subsidiary Absa Towers (Pty) Ltd hereafter referred to, collectively, as Absa, seek to review two decisions of the respondent, the […]
1. There have been a lot of ambiguities have arisen regarding the payment made to a non-resident entity for the grant of the use of computer software by a businessman in India for internal business purposes. 2. The Income Tax Department has been treating such payments as royalty and accordingly, bringing the same to tax in India.
Engineering Analysis Centre of Excellence Private Limited Vs CIT (Supreme Court of India); Civil Appeal Nos. 8733-8734 of 2018; Dated: 02/03/2021 Issues Involved : 1. The amounts paid by the residents in India to non-resident, foreign software suppliers; amounts to royalty, there by necessitating withholding of taxes under section 195 of Income Tax Act. 2. […]
